BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

) Application of ) ) ALASKA AIRLINES, INC. ) Docket DOT-OST-2004-19419 ) for an exemption pursuant to 49 U.S.C. 40109 ) )

APPLICATION FOR RENE WAL OF EXEMPTION

Communications with respect to this document should be addressed to:

Kyle Levine, Esq. Marshall S. Sinick, Esq. Associate General Counsel Charles F. Donley II, Esq. Commercial Law and Litigation Squire, Sanders & Dempsey L.L.P. Alaska Airlines, Inc. 1201 Pennsylvania Avenue, N.W. 19300 International Boulevard Washington, D.C. 20004 Seattle, Washington 98188 (202) 626-6651 msinick@ssd.com cdonley@ssd.com

Megan Lawrence, Esq. Counsel to Alaska Airlines, Inc. Managing Director, Government Affairs & Community Relations Alaska Airlines, Inc. 19300 International Boulevard Seattle, Washington 98188

DATED: May 25, 2010BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

) Application of ) ) ALASKA AIRLINES, INC. ) Docket DOT-OST-2004-19419 ) for an exemption pursuant to 49 U.S.C. 40109 ) )

APPLICATION FOR RENE WAL OF EXEMPTION

Alaska Airlines, Inc. (“Alaska”) hereby reque sts renewal of the exem ption authority granted

to it by the Department of Transportation (the “Department”) in the above-captioned docket to

perform scheduled foreign air transportation of pe rsons, property and mail between Los Angeles,

California, and Loreto, Mexico. This exemption authority expires on Au gust 28, 2010. Alaska

requests renewal of this authority for a two- year period and relies on the provisions of the

Administrative Procedure Act and Pa rt 377 of the Department’s proc edural regulation s to continue

its existing authorization in force pending a final decision on this renewal request.

In further support of its request fo r renewal, Alaska states as follows:

1. Alaska’s principal h eadquarters are located at 19300 International Boulevard,

Seattle, Washington. Alaska is incorporated under the laws of the State of Alaska and is a

wholly-owned subsidiary of Alaska Air Group, Inc. (“AAG”). AAG is incorporated under the

laws of the State of Delaware.Application for Renewal of Exemption Docket DOT-OST-2004-19419 May 25, 2010

2 2. Alaska is a citizen of the United States within the meaning of 49 U.S.C.

40102(a)(15). The president and at least two-thirds of Alaska’s directors and other managing

officers are U.S. citizens. Additionally, to Alaska’s knowledge, U.S. citizens hold at least

seventy-five percent of Alaska’s voting stock.

3. Alaska has repeatedly been found fit, wi lling and able to pr ovide interstate and

foreign air transportation. The De partment is requested to take official notice of Alaska’s

continuing fitness. See, e.g ., Order 2000-5-31.

4. Alaska holds out scheduled service between Los Angeles and Loreto under a

codeshare arrangement with Horizon Air Industrie s, Inc. (“Horizon). Under the two carriers’

agreement, Alaska displays its two-letter desi gnator code on flights operated by Horizon between

Los Angeles and Loreto. 1 Alaska does not serve Los Angele s-Loreto with its own aircraft and

does not plan to resume service in this market wi th its own aircraft. Alas ka would therefore have

no objection to withdrawal of its Los Angeles-Loreto designa tion provided it receives a

codeshare authorization that will permit it to continue to hold out such service without

interruption. The Department has found previously that Alaska ’s service in the Los AngelesLoreto market is consistent with the terms of the U.S.-Mexico bilateral agreement. 2

5. This renewal application does not rais e any environmental or energy concerns.

All flights will continue to be performed with aircra ft that meet all applicab le noise requi rements.

Similarly, approval of this appli cation will not result in a near-term increase in fuel consumption of

ten million gallons or more.

1 Horizon holds an exemption permitting it to operate between Los Angeles and Loreto. Notice of Action Taken

, Docket DOT-OST-2009-0180, August 18, 2009

2 See, Notice of Action Taken, Docket DOT-OST-2004-19419, August 28, 2008Application for Renewal of Exemption Docket DOT-OST-2004-19419 May 25, 2010

3 WHEREFORE , Alaska Airlines, Inc. respectfully requests that the exemption granted to

it in the above-captioned docket be renewed for an additional two-year period, as more fully

described herein.

Respectfully submitted,

________________________________ Marshall S. Sinick, Esq. Squire, Sanders & Dempsey L.L.P. 1201 Pennsylvania Avenue, N.W. Washington, D.C. 20004 (202) 626-6651 msinick@ssd.com

Counsel to Alaska Airlines, Inc.

DATED: May 25, 2010CERTIFICATE OF SERVICE

I hereby certify that one copy of the foregoi ng Application for Renewal of Exemption has this day been served on each of the follo wing individuals via telecopier or email.

___________________________ Marshall S. Sinick

DATED: May 25, 2010

hkamen@coair.com sascha.vanderbellen@delta.com sametta.c.barnett@delta.com jeffrey.manley@united.com anbird@fedex.com dvaughan@kelleydrye.com efaberman@wrf.com howard_kass@usairways.com dkirstein@yklaw.com jhill@dowlohnes.com mcmillin@woa.com pmurphy@lopmurphy.com jyoung@yklaw.com carl.nelson@aa.com